Employee Code of Conduct

Our Employee Code of Conduct ensures our commitment to integrity and legal compliance, and further describes how employees must behave in a wide range of business settings. With clear policies and guidance for business practices, the Code is the cornerstone of our ethics and compliance program, and is translated into five languages.

If employees observe something that does not comply with our Code and company values, we provide several tools for employees to provide anonymous and confidential reports of such activity. To ensure accountability, we provide a hotline operated by an independent, third-party organization. Access to this ethics hotline is available by phone or confidential web form, which can be found on our corporate website at www.thetorocompany.com/invest.

If questions of an ethical nature arise, employees are encouraged to discuss concerns with their supervisor, their human resources representative or the Legal Department. It is also important that all employees recognize they have a duty to report any suspected violations of our Employee Code of Conduct or Ethics Policies. Employees who, in good faith, report wrongdoing to management or supervisors will not be the subject of retaliation or other punishment.